Last Week in Federal Appeals #82
Appellate decisions from the week of April 6, 2026
“Rights, as important as they are, do not swing free and clear of the larger social compact. We live in a society that accords its citizens enormous benefits. In return, states can, in a measured way, require certain exactions and accommodations to the broader social interest. . . .West Virginia’s compulsory vaccination law does exactly that. It is a legitimate exercise of the state’s power to protect the health and well being of school children. Striking the law down would undermine not just our system of dual sovereignty, but also a long line of Supreme Court precedent.”
~Judge Wilkinson, Perry v. Marteney
DECISION SUMMARIES
Second Circuit
United States v. Goklu
The First Circuit held that exchanging bitcoin for cash can be considered transmission for money laundering purposes, and thus, the district court did not abuse its discretion when it instructed the jury that exchanging bitcoin for cash can constitute “transferring funds.”
Fourth Circuit
Perry v. Marteney
The Fourth Circuit held that West Virginia’s compulsory vaccination law, which does not allow for religious exemptions, does not violate the First Amendment because the law is a legitimate exercise of the State’s police power to protect the public health and public safety.
United States v. McLaurin
The Fourth Circuit held that, in case of conflict, a court’s written directive controls over its oral directive, treating the written judgment as “the court’s last word.”
Fifth Circuit
McNutt v. U.S. Department of Justice
The Fifth Circuit affirmed the district court’s decision that Congress’s prohibition of home distilleries violates the Constitution's Taxation and Necessary and Proper clauses.
Sixth Circuit
United States v. McNorriel
The Sixth Circuit held that a pro se criminal defendant, who also had standby counsel at trial, was not deprived of his Sixth Amendment rights to self-representation and to be represented during the critical stages of the proceeding when standby counsel participated— with the defendant’s consent— at sidebar discussions without the defendant.
Lovel v. County of Kalamazoo
The Sixth Circuit held that the overseer of a jail’s mental-health unit did not act with deliberate indifference when the overseer ordered special bedsheets to be provided to a suicidal prisoner but, through a miscommunication, normal bedsheets were provided and used by the prisoner to commit suicide.
Eighth Circuit
United States v. Farmer
The Eight Circuit held that the district court’s revocation of supervised relief and its subsequent sentencing of a drug trafficker—who had already served a full eight years of his original sentence—to an additional twelve months did not violate due process and trial rights under the Fifth and Sixth Amendments.
Briscoe v. St. Louis County
The Eight Circuit held that police officers did not violate a family’s Fourth Amendment rights when officers accidentally executed a search warrant— which included use of the SWAT team—on the family’s home rather than at the correct address of a suspect connected to a carjacking.
Ninth Circuit
Fresenius Medical Care Orange County v. Doe
The Ninth Circuit held that three of the four challenged provisions of California Assembly Bill No. 290, a bill which aims to prevent dialysis providers from profiting off patients receiving health insurance premiums, violate the First Amendment.
Tenth Circuit
United States v. Tew
The Tenth Circuit affirmed the district court’s holding that a couple convicted of fraud was not prejudiced by their consolidated trial because neither defendant timely moved to sever. The Court also held that the good-faith exception applied to the police’s execution of a defective search warrant used to secure cellphone data from one of the defendant’s cell phones.
Morphew v. Chaffee Cnty.
The Court upheld the district court’s decision that a section 1983 plaintiff failed to plausibly allege the absence of probable cause necessary for Fourth Amendment claims of malicious prosecution, fabrication of evidence, Franks violations, conspiracy, failure to intervene, and municipal liability. Likewise, the plaintiff’s Fourteenth Amendment claims were properly dismissed for lack of causation.
Eleventh Circuit
Hayes v. Dir., OWCP
The Eleventh Circuit held that the plain language of a regulation under the Federal Black Lung Benefits Act requires only that a claimant prove that he/she worked for 125 days in a coal mine during a calendar year.
Dish Network L.L.C. v. Fraifer
The Eleventh Circuit affirmed the district court’s ruling that a telecommunications provider committed copyright infringement when it sold elements of Dish Network’s exclusive ownership rights of certain Arabic-language channels without Dish’s permission.
DC Circuit
Alon Refining Krotz Springs, Inc. v. Env’t Prot. Agency
The D.C. Circuit held that the EPA’s interpretation of its own regulation requiring oil refineries to meet the definition of “small refineries” in order to petition the EPA for exemptions was contrary to the provision’s plain meaning.
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